California Appellate Tracker

Pulliam v. HNL Automotive Inc. (2021)

February 2, 2021

Disagreeing with Lafferty II and Spikener, this decision holds that “recovery” as used in the FTC Holder Rule includes only damages, not attorney fees, and so the consumer may recover unlimited attorney fees against the holder of his or her contract on claims against the dealer. The decision also concludes that the FTC 2019 interpretation of the Holder Rule’s second sentence is not entitled to deference because the FTC reached that conclusion after soliciting comments only on other aspects of the Holder Rule.

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Pulliam v. HNL Automotive Inc. (2021)

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